List of topics
- Climate neutrality plans: application at sub-installation instead of installation level
a. The precedent of the activity level changes applied at sub-installation level
b. The reference to “product benchmarks” in article 10a paragraph 1
c. Only article 10b(4) “shall be read as to referring to installation level”
d. Inconsistency with the legal wording of the Directive (penalty also to fall back benchmarks
sub-installations)
e. Distortion of competition among installations - Climate neutrality plans: targets and milestones based on measures and investments instead of
emissions reduction - Energy efficiency conditionality: sufficient time for implementing audits’ recommendations
- Historical activity level
The whole document can be downloaded here.